Income Tax : The FAQs explain the revised CBDT guidelines on compounding offences under the Income-tax Act effective from 17 October 2024. They...
Income Tax : The article explains who can file appeals before the Income Tax Appellate Tribunal, the orders that are appealable, applicable tim...
Income Tax : The Tribunal held that additions cannot stand without a clear link between seized material and the assessee. It ruled that third-p...
Income Tax : Judicial rulings clarify that satisfaction for initiating action against other persons in search cases must be recorded promptly. ...
Income Tax : CBDT's new Compounding of Offence Guidelines (2024) simplify the process but maintain strict compliance rules. Learn about eligibi...
Income Tax : Learn about the new block assessment provisions for cases involving searches under section 132 and requisitions under section 132A...
Income Tax : Gujarat High Court held that rejection of a Vivad se Vishwas declaration was invalid because final assessment arose from survey pr...
Income Tax : The Tribunal held that an addition under Section 69 could not be sustained solely on the basis of a seized loose sheet without ind...
Income Tax : The ITAT held that assessments under Section 153A were invalid because no search warrant was issued in the assessee’s name. As t...
Income Tax : The ITAT Hyderabad held that the assessment orders were time-barred under Section 153 despite the DRP process. Both assessments we...
Income Tax : The ITAT held that limitation under Section 153B had to be computed from the searched person's last panchanama, making the assessm...
Income Tax : Central Government has decided to extend the time limits to 30th June, 2021 in the following cases where the time limit was earlie...
Income Tax : Availability of Miscellaneous Functionalities related to ‘Selection of Case of Search Year’ and ‘Relevant Search...
The Tribunal clarified that expenditure disallowances do not qualify as assets under section 149(1). Without asset-based escaped income, reopening beyond three years is barred. This offers strong protection against belated reassessments.
The Tribunal held that an assessment framed without issuing a compulsory notice under section 153C lacks jurisdiction. Even seized material cannot cure this foundational defect, rendering the order void ab initio.
ITAT Delhi ruled that granting a common approval for several assessment years violates statutory safeguards. Search assessments collapse if approval is mechanical or omnibus in nature.
Tribunal held that TDS liability under section 194-IA cannot arise unless Revenue proves that payment was actually made. Mere third-party statements were found insufficient to treat buyer as an assessee in default.
The decision reiterates that section 150 is subject to section 150(2) and cannot revive time-barred or jurisdictionally invalid assessments. Directions to reopen were struck down as unlawful.
The Tribunal held that completed assessments cannot be disturbed under section 153C without incriminating material found during search. Additions based solely on third-party data were ruled invalid.
The issue was whether settled losses could be ignored in a search assessment without incriminating material. The Tribunal held that the AO must start from the last assessed income and allow already determined losses.
Rejecting contradictory treatment, the Tribunal ruled that the Revenue cannot approbate and reprobate by accepting the lender’s scrutiny while taxing the borrower under section 68. The addition was therefore deleted.
The issue was whether Section 153C proceedings for seven years could rest on a single satisfaction note. ITAT held that absence of year-wise satisfaction vitiates jurisdiction, quashing all assessments.
The Tribunal ruled that CIT(A) exceeded jurisdiction by remanding a completed scrutiny assessment. The decision clarifies that remand powers apply only to Section 144 assessments, not regular ones.
